Human Rights Defense Center v. Baxter County, Arkansas, No. 19-2096 (8th Cir. 2021)Annotate this Case
HRDC filed suit against Baxter County under 42 U.S.C. 1983, alleging that the Jail's postcard-only policy violates HRDC's First Amendment right to communicate with Jail inmates. HRDC also alleged that the Jail's rejection of HRDC's mailings violated HRDC's Fourteenth Amendment procedural due process rights to notice and an opportunity to appeal the Jail's decisions. The district court initially granted partial summary judgment in favor of HRDC. After a bench trial, the district court held that the postcard-only policy was reasonably related to legitimate penological goals and did not violate HRDC's First Amendment rights. The district court awarded HRDC four dollars in nominal due process damages for its four discrete August 2016 mailings.
The Eighth Circuit affirmed the due process ruling and concluded that the district court did not err in granting only nominal damages where HRDC failed to prove actual injury flowing directly from the technical due process violation in August 2016. The court vacated the First Amendment ruling where the district court made no finding of fact regarding whether HRDC proved its assertion that the postcard-only policy results in "a de facto total ban" on Jail inmates accessing HRDC's materials. The court explained that it is necessary for the court to have a finding on what, if any alternative means are available to HRDC to exercise its First Amendment interest in access to prisoners. Therefore, the court remanded for further proceedings.